In an interview with European Gaming, Michael Carlton, founder and chief executive officer of 21.com, explains why the operator is proving its model in a small number of markets before expanding, what AI changes across personalisation, trading, player safety, and support, and why he believes the gap between legacy platforms and purpose-built ones is the opening 21.com can exploit over the next two to three years.
Key findings
- On year-one market strategy: ‘We’re not trying to launch everywhere at once.’
- On what top-three actually means: ‘A top-three operator by revenue that players don’t trust or enjoy using isn’t sustainable.’
- On building without legacy systems: ‘Because we built without legacy infrastructure, AI isn’t sitting on top of the product as an add-on.’
- On protecting culture as the team grows: ‘Culture is easy to describe at 20 people and much harder to protect at 100 or 200.’
- On the window left by legacy platforms: ‘That’s the gap I think 21.com can exploit over the next two to three years.’
Why year one is about a small number of markets
European Gaming: Which jurisdictions are you prioritising in year one, and what does ‘top-three’ actually look like in practical terms?
Michael Carlton: We’re not trying to launch everywhere at once.
‘Year one is about proving the model in a small number of markets where we can genuinely compete on product and experience from day one, then using that as the template for expansion rather than spreading resources too thin.’
As for what ‘top-three’ means in practice, it’s not just one number. It’s a combination of market share, yes, but also brand recognition and, most importantly, player retention and satisfaction.
A top-three operator by revenue that players don’t trust or enjoy using isn’t sustainable. We’re building for the long-term measure of success, not a short-term spike.
We’ve got a range of markets we’re looking at, and are in the process of securing a number of licences, so the scope for our operations will hopefully expand in the coming months.
What AI actually changes day to day
EG: What does AI actually do differently at 21.com day-to-day?
Michael Carlton: This is where I’d push back gently on the idea that AI is one thing. For us, it touches several parts of the business, and the value is different in each.
- On personalisation, it means the product adapts to how an individual player actually behaves, rather than putting everyone through the same generic journey.
- On trading, it means we can react and price faster than a team relying purely on manual processes.
- On player safety, it means we can spot patterns of concerning behaviour earlier and intervene before it becomes a problem, rather than after the fact.
- On customer support, it means players get faster resolution on the simple things, freeing our people to focus on the situations that genuinely need a human.
The common thread is that none of this was retrofitted.
‘Because we built without legacy infrastructure, AI isn’t sitting on top of the product as an add-on. Instead, it’s part of how the product was designed from the outset.’
This gave us the agility and product flexibility to really stand out as we enter a new market.
Protecting culture beyond the founding team
EG: Why are people the differentiator for 21.com?
Michael Carlton: Culture is easy to describe at 20 people and much harder to protect at 100 or 200.
The way we’re approaching it is by being deliberate about who we hire beyond the founding group, not just for skills but for the same appetite to build something rather than maintain something.
Practically, that means giving people real ownership over their part of the business early, rather than layering in bureaucracy as we grow.
It’s not a small thing to say that we’re a team that works well together, enjoys an aligned sense of humour, and truly embraces coming to work each day.
This is crucial, as it’s also a clear sign of how the team handles pressure.
‘Gaming is a high-intensity industry, and a team that can stay positive under that pressure tends to outperform one that treats every setback as a crisis.’
Bolt-on AI versus building it into the core
EG: What does the focus on AI mean for 21.com’s integration roadmap, and how do competitors compare?
Michael Carlton: Where I think the industry splits is between operators treating AI as a bolt-on feature versus building it into the core product.
We see this across the board with our product, from our seamless payment options to rolling out great products quickly. A lot of established operators are adding crypto payments as one more option on an already crowded payments page, without rethinking the player journey around it. We’ve built it in as a first-class part of the experience.
As for competitors adapting, some will move fast because they see the commercial upside clearly. Others will be slower simply because of the legacy problem we’ve talked about.
‘It’s much harder to bolt modern payment rails and AI-driven personalisation onto a platform that wasn’t built to support either.’
About 21.com
21.com is an online casino and sportsbook led by founder and chief executive officer Michael Carlton. The company says its technology stack was built from scratch rather than adapted from a legacy platform, with crypto payments and AI-led operations central to the product. Carlton is a British-born Chartered Accountant who spent 13 years at EY before joining BetVictor in 1997, and served as its chief executive officer and co-owner from 2002 until 2014.
